The short version:
In April 2025, the U.S. Fish and Wildlife Service and the National Marine Fisheries Service proposed changes to the Endangered Species Act (ESA). They aim to redefine the term “harm” by excluding habitat modification or degradation from its scope.
The Coalition for Sonoran Desert Protection strongly opposes this proposal — please join us in speaking up before the public comment period ends on May 19, 2025.
What’s being proposed, and why it matters
- Currently, the definition of “harm” to endangered species is understood to include indirect as well as direct injuries. Habitat loss is the second leading cause of species endangerment in the United States (USGS, 2022).
- By altering this definition, the protection offered by the word “harm” loses its meaning.
- If this proposal were to pass, it would create opportunities for developers, miners, and oil and gas companies to destroy endangered species habitat with no accountability for incidental loss of endangered species.
Habitats need more protections right now, not less!
The ESA and Pima County, today
The ESA played a key role in shaping conservation efforts in Pima County. The listing of the Cactus Ferruginous Pygmy Owl under the ESA in 1997 was the catalyst for the creation of the Coalition for Sonoran Desert Protection and the Sonoran Desert Conservation Plan (SDCP), both in 1998.
- We’re lucky to have strong local protections here in Pima County, which help protect habitats even if the ESA changes.
- The Multi Species Conservation Plan (MSCP), approved in 2016 as part of the Sonoran Desert Conservation Plan, is how Pima County complies with the ESA — it’s Pima County’s habitat conservation plan.
- It provides protections for 44 species, their habitats, and ecosystem processes.
- In order to be approved under the permit allowing for “incidental take” (which just means accidental harm done to species indirectly through habitat loss, i.e. “taking” of habitat) the MSCP requires a habitat conservation plan for a development.
Photo credit: Frank Staub.
What this could mean for the region
- If ESA protections are weakened, it could undermine Pima County’s MSCP and efforts to draft a habitat conservation plan for the City of Tucson.
- The ESA rule change is not retroactive — so the MSCP’s foundational permit is not at risk, but incentives to participate may be reduced. (Remember: those who participate in the MSCP agree to creating a habitat conservation plan for their project.)
- The MSCP only covers county-controlled lands and private lands requiring county action such as a development permit. That means other lands are still subject to changes in how the ESA is applied and enforced.
Here’s how you can help today >>
Submit a public comment.
Emphasize that you oppose changing the definition of the word “harm”.
Comment Deadline: May 19, 2025, midnight EST
Need inspiration?
You can read any of the 100,000+ comments. That’s a huge number, but it’s still important that we all speak up and help that number grow!
“Hundreds of Thousands of people are pleading with you not to change the ESA’s definition of Harm to exclude habitat loss. It’s a well-known *fact* that habitat loss is a leading cause of extinction. Animals with nowhere to live, with nothing to eat, with nowhere to breed, are dead. This is a fact. You know this. Your superiors know this. I, personally, as someone who has taken great pleasure in exploring the outdoors of our great country, am begging you to think this through. I’ve spent time hiking the forests of Missouri, gazing upon the wonder of the west’s prairies, feeling the terror one can only feel at the edge of a canyon, and hearing the coyotes wail in the desert sunset of Arizona. You would rob me of this, my family, and future generations by signing the death certificate of thousands of endangered species with this proposal. Do not do this. Please.”
“Especially in the Sonoran Desert of South Arizona so many species there only exist in that specific habitat and any destruction would be devastating for the local species”
“Our lands and their ecosystems are too precious for us to lose.”
Tags: cactus ferruginous pygmy owl, endangered species act, Habitat Conservation Plan, mscp, Rule Change, SDCP, Section 10 Permi, Section 10 Permit, Sonoran Desert Conservation Plan“As an environmental scientist, I have seen how fragile ecosystems are—and how even small habitat disruptions, like the removal of nesting trees or alteration of water sources, can determine the survival of a species. Redefining “harm” to exclude habitat modification would undo decades of progress and violate the moral responsibility we share to protect vulnerable wildlife and the ecosystems that support them.”